IA-9(1): Information Exchange

Most identity failures happen at boundaries: between applications, across environments, and when a third party needs access to your systems. IA-9(1): information exchange requirement is the requirement-level hook that forces you to define how identity-related information moves between systems, under what trust model, and with what protections. In practice, this is where SSO federations, API-to-API service identities, SCIM provisioning feeds, directory sync, PAM integrations, and even “just share the user list” workflows either become controlled and auditable or stay informal and risky.

For a Compliance Officer, CCO, or GRC lead, the goal is not to design authentication from scratch. Your job is to make the information exchange pathways explicit, approved, and testable, and to ensure the control owner can produce evidence on demand. That means you need an inventory of identity exchanges, minimum technical standards (protocols, encryption, signing, token handling), third-party agreements where applicable, and operational checks that prove the exchanges work as designed and fail safely when something changes.

This page gives you requirement-level implementation guidance you can hand to IAM, security engineering, and integration teams and then assess quickly.

Regulatory text

Control reference: “NIST SP 800-53 control IA-9.1.” ¹

Operator interpretation (what you must do):
You must define and control the mechanisms used to exchange identity and authentication information between systems (including with third parties), and you must be able to show that those exchanges are authorized, protected, and managed consistently. The assessable outcome is straightforward: identity information does not move across a boundary unless you have an approved method, a known trust relationship, and supporting evidence. ²

Plain-English interpretation of the requirement

IA-9(1): information exchange requirement is about preventing “implicit trust” when identities cross system boundaries.

In practical terms, you are trying to answer, for every identity integration:

• What information is exchanged? (assertions, attributes, group membership, tokens, keys, certificates)
• Who is allowed to exchange it? (systems, services, third parties, administrators)
• How is trust established? (federation metadata, mutual TLS, key exchange, certificate pinning, signed tokens)
• How is it protected? (encryption in transit, signing, replay protection, token lifetime controls)
• How is it governed? (approval workflow, change control, monitoring, periodic review)

If you cannot answer those questions per exchange path, you are not “doing IA-9(1)” in an assessable way, even if your users can log in.

Who it applies to (entity and operational context)

Entity scope:

• Federal information systems and contractor systems handling federal data commonly map to NIST SP 800-53 requirements, including this control. ²

Operational scope (where IA-9(1) shows up):

• SSO federation between your IdP and SaaS applications (SAML/OIDC)
• API gateways and service-to-service authentication (OAuth client credentials, mTLS)
• Directory synchronization and identity provisioning (SCIM, LDAP sync, HRIS feeds)
• Privileged access tools integrating with directories and vaults
• Third-party support access (break-glass accounts, just-in-time provisioning)
• Cross-domain access (dev/test/prod boundary crossings, multi-tenant access patterns)

If it is an identity boundary, treat it as in scope.

What you actually need to do (step-by-step)

Step 1: Assign ownership and define the control boundary

• Name a control owner (typically IAM lead or security architecture) and a GRC accountable (you).
• Define the system boundary: which environments and applications are included, and which exchanges are “external” (third party, partner) versus internal.

Deliverable: IA-9(1) control narrative with named owners and in-scope systems.

Step 2: Build an “identity exchange inventory”

Create a register of every identity-related exchange. Minimum fields:

• Source system (IdP/directory/service)
• Destination system (app/SaaS/API/third party)
• Exchange type (SSO, provisioning, token exchange, certificate trust, directory sync)
• Protocol/mechanism (SAML, OIDC, OAuth, mTLS, SCIM, LDAP)
• Data elements shared (attributes, groups, entitlements)
• Trust material (certs, keys, metadata URLs, JWKS endpoints)
• Approval authority and ticket/change reference
• Monitoring/log source

Practical tip: Start with your IdP application catalog and your API gateway auth policies. That usually surfaces most exchanges quickly.

Deliverable: Identity Information Exchange Register.

Step 3: Standardize approved exchange patterns (your “allow list”)

Define a small set of approved patterns with minimum requirements. Example patterns:

• Workforce SSO to SaaS: SAML or OIDC with signed assertions/tokens; enforced MFA upstream; restricted attributes; documented attribute mapping.
• Service-to-service: mTLS with managed certificates or OAuth with short-lived tokens; no long-lived shared secrets in code; rotation documented.
• Provisioning: SCIM with scoped service accounts; least-privilege attribute write permissions; deprovisioning behavior defined.

Make the patterns enforceable by:

• Configuration baselines in IdP
• API gateway policies
• Network egress controls
• App onboarding checklists

Deliverable: “Approved Identity Exchange Standard” (a short standard plus checklists).

Step 4: Put an approval and change process around new exchanges

Require that any new identity exchange (or material change) goes through:

• Security review (protocol, trust model, attribute minimization)
• Data classification check (are regulated attributes shared?)
• Third-party due diligence trigger (if external)
• Change management ticket with implementation evidence

Control objective: No “shadow SSO,” no informal directory sync, no untracked support access.

Deliverable: Workflow (ticket template + required fields) tied to the exchange register.

Step 5: Implement technical controls that prove trust and protection

Your engineering teams should be able to demonstrate, per pattern:

• Encryption in transit for the exchange endpoints
• Token/assertion signing validation and key management
• Replay protections and token lifetime controls
• Service account scoping and credential rotation approach
• Strong separation of environments (no prod assertions accepted in non-prod and vice versa)

As a GRC lead, your job is to ensure these are documented and that configurations are retrievable during an assessment.

Deliverable: Configuration evidence pack (screenshots/exports) for representative integrations, plus a method to reproduce it.

Step 6: Monitor and review exchanges

Define what “good operations” looks like:

• Logging for authentication events and provisioning actions
• Alerting on abnormal patterns (new relying party, sudden attribute changes, failed signature checks)
• Periodic access review for third-party integrations and service accounts
• Periodic review of the exchange register for completeness

Deliverable: Monitoring runbook entries and review records.

Required evidence and artifacts to retain

Assessors typically want traceability from requirement → implementation → operation. Keep:

• Identity Information Exchange Register (current, versioned)
• Approved Identity Exchange Standard (patterns, minimum requirements)
• Architecture diagrams showing trust boundaries and identity flows
• IdP configuration exports (metadata, relying party settings, attribute mappings)
• API auth policy configs (gateway policies, OAuth scopes, mTLS settings)
• Certificate/key management records (issuance, rotation procedure, ownership)
• Tickets/approvals for each new or materially changed exchange
• Third-party agreements that address identity integration responsibilities (where applicable)
• Logs and monitoring evidence (sample events, alert rules, dashboards)
• Periodic review attestations (who reviewed, what changed, what exceptions exist)

If you can’t produce artifacts on demand, the most common finding is “control not implemented” or “not operating effectively,” even if the technology is in place.

Common exam/audit questions and hangups

Use these to pre-brief your control owner:

• “Show me all systems that consume identity assertions from your IdP. Where is that list maintained?”
• “How do you approve a new SSO integration? What evidence shows approval occurred before go-live?”
• “Which attributes do you release to each relying party, and how do you prevent over-sharing?”
• “How do you manage signing keys/certificates? Show rotation evidence.”
• “How do you detect an unauthorized integration or a change to federation metadata?”
• “How do third parties obtain access, and how is that access terminated?”

Hangup to expect: Teams will say “it’s in the IdP” but not have a controlled export, diagram, or review record.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails IA-9(1)	Avoid it by
No inventory of exchanges	You can’t prove what exists or what is approved	Maintain the exchange register and reconcile against IdP/app catalogs
Over-sharing attributes by default	Data exposure and privilege creep	Use attribute minimization per relying party; document mappings
Long-lived shared secrets for integrations	Hard to rotate; easy to leak	Prefer mTLS or short-lived tokens; document rotation ownership
Informal third-party support access	Access persists beyond need; weak accountability	Require a defined method (JIT/PAM), approval, and logging
No evidence pack	Control may be “real” but unprovable	Pre-build an assessor packet for representative flows
Environment mixing	Test identities or tokens accepted in prod	Separate trust stores, issuers, and audiences per environment

Enforcement context and risk implications

No public enforcement cases were provided in the supplied sources for this requirement, so you should treat this section as risk context rather than case law.

Operational risk is clear: uncontrolled identity information exchange creates pathways for account takeover, privilege escalation through group/role injection, unauthorized access by third parties, and failures to deprovision. The compliance risk is also predictable: assessors often write findings when identity integrations exist but cannot be enumerated, approved, and evidenced consistently.

If you use Daydream to manage control ownership and recurring evidence, the most efficient pattern is to map IA-9(1) to a named owner, link each identity exchange record to its approval artifact, and schedule recurring evidence pulls from the IdP and API gateway so audit readiness is continuous. ¹

Practical 30/60/90-day execution plan

First 30 days (Immediate stabilization)

• Assign control owner and publish a one-page IA-9(1) control narrative.
• Stand up the Identity Information Exchange Register and populate it from the IdP app list plus top integrations.
• Define “approved exchange patterns” for SSO and provisioning, even if initial scope is limited.
• Choose the evidence set you will retain for each exchange and create a shared repository structure.

Next 60 days (Standardize and enforce)

• Put a ticketed approval workflow in front of new exchanges and material changes.
• Normalize attribute release policies (default deny, explicit allow per relying party).
• Document key/cert lifecycle responsibilities for federation signing and mTLS.
• Build an assessor-ready evidence packet for a small number of high-impact exchanges (critical SaaS, core APIs, key third parties).

By 90 days (Operate and prove)

• Reconcile the exchange register against reality (IdP catalog, API gateway, directory sync jobs).
• Add monitoring and alerting for suspicious identity exchange events relevant to your environment.
• Run a tabletop review: “If a third party is terminated today, what identity exchanges must be disabled and how do we prove it?”
• Schedule recurring reviews and evidence refresh so you can answer audit requests without a scramble.

Frequently Asked Questions

Does IA-9(1) only apply to SSO?

No. Treat SSO, provisioning (SCIM/directory sync), service-to-service authentication, and third-party support access as identity information exchange paths if identity or authentication data crosses a boundary.

What is the minimum artifact set an auditor will expect?

An exchange inventory, an approved standard/pattern, approval/change records for sampled exchanges, and configuration/log evidence showing the exchange is protected and operating consistently.

We have dozens of SaaS apps. Do we need deep evidence for every single one?

Maintain the register for all of them, then prepare deep evidence for representative samples and the highest-risk apps. Keep a repeatable export method so you can expand the evidence set quickly.

How do we handle third-party integrations that “only” use API keys?

Treat that as a high-risk exchange method unless you can show strong controls around key issuance, storage, rotation, scoping, and monitoring. Prefer exchange patterns that support stronger trust, then document exceptions and compensating controls.

Who should own IA-9(1): IAM, security engineering, or GRC?

IAM or security architecture typically owns implementation, while GRC owns governance, testing, and evidence. Name both roles explicitly so approvals and evidence collection do not fall through gaps.

What’s the fastest way to find “shadow” identity exchanges?

Compare your IdP app catalog and directory sync jobs against procurement records and system inventories, then ask application owners how users are created and how access is granted. Any answer that bypasses the standard patterns is a candidate shadow exchange.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5